In Flanagan et al v. Girl Scouts of Suffolk County, Inc. et al, 23-7900-cv, 2025 WL 1501751 (2d Cir. May 27, 2025), the court, inter alia, held that plaintiff plausibly alleged race discrimination under 42 U.S.C. § 1981 and the New York State Human Rights Law (NYSHRL), and vacated a lower court order holding otherwise.…
Read More Race Discrimination Claims Plausibly Alleged; 2nd Circuit Vacates DismissalIn Smith v. The City of New York, No. 153568/2024, 2025 WL 1446812 (N.Y. Sup Ct, New York County May 20, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s claims of race and arrest-history discrimination. From the decision: Under both the NYSHRL and NYCHRL, a complaint need only “give fair notice of…
Read More Race and Arrest Record Discrimination Claims Survive Dismissal Against the City of New YorkIn Lobosco v. City of New York, No. 152196/2024, 2025 WL 1446815 (N.Y. Sup Ct, New York County May 20, 2025), the court, inter alia, denied defendant’s motion to dismiss plaintiff’s discrimination and hostile work environment claims asserted under the New York State and City Human Rights Laws. In her complaint, plaintiff “details a pervasive…
Read More Sex Discrimination & Hostile Work Environment Claims Against City of New York Survive DismissalIn Dorilus v. DCAS, No. 101225/2023, 2025 WL 1238058 (N.Y. Sup Ct, New York County Apr. 24, 2025), the court granted defendant’s motion to dismiss plaintiff’s claim of religious discrimination under the New York State and City Human Rights Laws. From the decision: In DCAS’s supporting papers, it assumes that this cause of action is…
Read More Religious Discrimination Claim Dismissed, in Light of Failure to Identify a “Religious Belief”In Sean C.I.R. v. Nexstar Media Group Inc., No. 150543/2024, 2025 WL 944582, 2025 N.Y. Slip Op. 30975(U), 7–8 (N.Y. Sup Ct, New York County Mar. 28, 2025), the court, inter alia, granted defendant’s motion to dismiss plaintiff’s claims of a race-based hostile work environment under the New York State and City Human Rights Laws.…
Read More Race-Based Hostile Work Environment Claims DismissedIn Smith v. National Grid USA, 2:21-cv-6899 (NJC) (LGD), 2025 WL 1248676 (E.D.N.Y. April 30, 2025), the court, inter alia, denied defendant’s motion for summary judgment on plaintiff’s race-based hostile work environment claims. From the decision: [T]here are numerous genuine disputes of material fact concerning Smith’s hostile work environment claims—under both the higher federal standard…
Read More Race-Based Hostile Work Environment Claims Survive Summary Judgment; Allegations Include “Shine Box” and “Monkey” CommentsIn Wright v. White Plains Hospital Medical Center, No. 2023-05430, 64135/19, 2025 N.Y. Slip Op. 02371, 2025 WL 1173144 (N.Y.A.D. 2 Dept., Apr. 23, 2025), the court affirmed the award of summary judgment dismissing plaintiff’s claims of pregnancy discrimination under Title VII of the Civil Rights Act of 1964 and the New York State Human Rights…
Read More Pregnancy Discrimination Claims Properly Dismissed, 2nd Department HoldsIn Cohen v. Arnot Health, Inc. et al, 2025 WL 1197854 (2d Cir. April 25, 2025), the U.S. Court of Appeals for the Second Circuit affirmed the lower court’s award of summary judgment on plaintiff’s age discrimination claim asserted under the Age Discrimination in Employment Act (ADEA) and the New York State Human Rights Law…
Read More Age Discrimination Claims Properly Dismissed, Absent Adverse Employment ActionIn Noh v. Admarketplace, Inc., 24 Civ. 2107 (ER), 2025 WL 965882 (S.D.N.Y. March 28, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s sex- and race-based hostile work environment claims asserted under Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 1981, and the New York State and City…
Read More Hostile Work Environment Claim, Based on Race and Sex, Survive DismissalIn Lyu v. Alfa Chemistry Inc. et al, 23-CV-7951 (EK)(ST), 2025 WL 1093134 (E.D.N.Y. April 13, 2025), the court, inter alia, denied defendants’ motion to dismiss plaintiff’s claim of sex-based discrimination under the New York State Human Rights Law. The court summarized, and applied, the law as follows: The elements of a disparate treatment claim…
Read More NYSHRL Wrongful (Sex-Based) Discrimination Claim Survives Dismissal